CBP Initial Determination Malaysia Transshipping February 2022 | Page 32

Artist Kitchen ’ s entries may be [ activity ], or [ activity ] that should have been declared as [ type

290 c . Ivy Zhang

Additional record information indicates the MSW Companies source QSP from China . Ivy Zhang ( Ms . Zhang ) indicated on social media platforms that she is the sales manager at Xiamen Laituosi Building Materials Co ., Ltd . ( Xiamen Laituosi ), a Chinese producer of QSP . 291 Her social media page indicates she has a Xiamen Laituosi email address ( i . e ., an email address ending in “ ltsstone ” which is Xiamen Laituosi ’ s domain name ). 292 Xiamen Laituosi ’ s social media page indicates its contact information ( i . e ., email and WhatsApp ) is the same as Ms . Zhang ’ s contact information . 293

Social media posts also indicate Ms . Zhang is a “ manager ” and “ quartz export manager ” for MSW . 294 Social media posts by Ms . Zhang also indicate she is involved in the export of Chinese QSP from Malaysia . For example , her posts contain many hashtags indicating the country of origin is China and also indicating they can be shipped from Guangdong through Malaysia to the United States “ without high tariffs .” 295 In one social media post Ms . Zhang states :

Hello , This is Ivy from Malaysia , a QUARTZ export MANAGER at MSW BUILDING SUPPLY SDN . BHD . We are a professional quartz surfacing manufacturer and fabricator , 100 hectares manufacturing area , equipped with 12 automatic quartz slab production line and “ state-of-the-art ” machinery . 296

However , in various CF28 responses , members of the MSW Companies indicated they had no production capacity , rather they are trading companies which purchase the QSP they sell . 297 An examination of Xiamen Laituosi ’ s website indicates that , in fact , its “ production base has about 100 hectares manufacturing area , equipped with 12 automatic quartz slab production line and “ state-of-the-art ” machinery .” 298 In sum , record evidence indicates that one of the sources of the MSW Companies ’ QSP is Xiamen Laituosi , a Chinese QSP producer .

d . Country of Origin Information for the MSW Companies

CBP requested information concerning the country of origin for several entries by Flowery Stone and Nio purportedly manufactured by the MSW Companies . Flowery Stone and Nio provided

290

Id .

291

See Malaysian Companies Memo at “ Xiamen Laituosi .” Ms . Zhang refers to herself in different social media

posts as a “ professional quartz stone supplier ” and “ quartz stone export manager ” for Xiamen Laituosi . Id .

292

Id .

293

Id . Social media posts indicate that Ms . Zhang also recently worked for Fabulous Group ( Xiamen ) Co ., Ltd ., which is a group of companies engaged in QSP production . Although one social media post indicates she recently left this company .

294

Id . CBP notes Ms . Zhang appears to have scrubbed her social media posts of any mention of MSW around the time the CF28s were issued to the Importers under investigation .

295

Id .

296

See Malaysian Companies Memo at Xiamen Laituosi .

297

See Big D ’ s CF28 Response ; Kingway ’ s CF28 Response ; and Nio ’ s CF28 Response .

298

See Malaysian Companies Memo at Xiamen Laituosi .
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